格尔夫波特信笺

二零零八年十二月二十四日

Securities and Exchange Commission

纽约F街100号.E.

7010邮件站

华盛顿特区.C. 20549

亲爱的女士. 讨厌:

On behalf of Gulfport Energy Corporation, a Delaware corporation (the “公司”), we respond to the comments received from Ms. 莉莉讨厌, on behalf of the Securities and Exchange Commission 工作人员 (the “工作人员”), in a telephone message to the 公司 on Friday, 12月19日, 2008 relating to our responses to the 工作人员’s comment letter, 12月3日, 2008年(the评论 信”), relating to the 形成10 - k, 形式的10 and 签署的委托书. In that telephone message, the 公司 was requested to provide proposed disclosure in response 工作人员 评论s 3 and 6 and any other comments where such disclosure could make the review faster. In response, we have provided additional information with respect to 评论s 3, 4 and 6.

Financial Statements

Note 5 – Property and Equipment, page F-14

回应: In future filings, we will include additional disclosures pertaining to unproved properties and major development projects as required under Rule 4-10(c)(7)(ii) of Regulation S-X. Representative disclosure would read as follows:

The following is a summary of Gulfport’s oil and gas properties not subject to amortization as of 12月31日, 2007:

Securities and Exchange Commission

二零零八年十二月二十四日

页面 2

At 12月31日, 2007, 大约1美元,106,000 of oil and gas properties related to the 公司’s Belize properties was excluded from amortization as they related to non-producing properties. 除了, 大约34美元,540,000 of non-producing leasehold costs resulting from the 公司’s acquisition of West Texas Permian properties was excluded from amortization at 12月31日, 2007. 大约1美元,632,000 of non-producing leasehold costs related to the 公司’s Southern Louisiana assets was also excluded from amortization at 12月31日, 2007. At 12月31日, 2006, 大约1美元,459,000 of non-producing leasehold costs related to the 公司’s Southern Louisiana assets was excluded from amortization.

Subject to industry conditions, evaluation of most of these properties and the inclusion of their costs in the amortized capital costs is expected to be completed within three to five years.

Engineering 评论s

一般

回应: The requested information was delivered to the 工作人员 supplementally on Friday, 12月19日, 2008.

Securities and Exchange Commission

二零零八年十二月二十四日

页面 3

Properties, page 23

Proved Oil and Gas Reserves, page 23

If your percentage of proved developed non-producing reserves is significant, please expand your disclosure to include this information.

Because of your large percentage of undeveloped reserves, please expand your disclosure to include the amount and percentage of undeveloped reserves that you converted to developed reserves in each of the last 三年.

回应: We will expand our disclosure to include the SEC definition of proved reserves as found in Rule 4-10(a) of Regulation S-X.

When material, we will disclose in future filings the percentage of proved developed non-producing reserves. Representative disclosure would read as follows:

截至12月31日， 2000    ,     % of our total proved reserves were classified as proved developed non-producing.

Because of our large percentage of undeveloped reserves, we will also expand our disclosures to include the amount and percentage of undeveloped reserves that we converted to developed reserves in each of the last 三年. Representative disclosure would read as follows:

在200年    , 200     和200年    ，我们转换了             英国央行,             英国央行和             英国央行, respectively, of undeveloped reserves to developed reserves, representing     %,     %,     %, respectively, of our proved reserves.

If you have any questions with respect to the foregoing, please call the undersigned at (405) 848-8807.

真诚地,

Michael G. 摩尔

附件

总法律顾问

赛斯R. 莫莱P.C.

阿金·甘普·施特劳斯 hau & 菲尔德律师事务所